Unless otherwise stated below, NewsNow Publishing Limited (“NewsNow”, “we”,
“us” or “our”) is the data controller of the personal data that we
collect and process. For details on how to contact our Data Protection Officer, please see section 9 below.

Where indicated, we contract third parties to process data on our behalf. These third parties act as data processors, which means
that they act only on our instructions and are not authorised to share the data that they process for us with anyone else, and that
we remain the controller of such data.

By continuing to use any of our sites, you acknowledge our collection, storage and use of your personal information as
described below.

2 The data we collect about you

The term “personal data”, or “personal information”, means any information
about an individual from which that person can be identified. It does not include data where the identity has been removed
(i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you in the following circumstances:

They do not include sites we link to that are owned and/or operated by third parties. We are not responsible and accept no
liability for the privacy practices of such sites or other services. This Privacy Policy applies only to our own sites
and services.

Website functionality

We aim to provide our users with useful services through site functionality, some of which depends on our collecting and storing information relating to your preferences or browsing behaviour.

When you are not signed into a NewsNow account, we store this in persistent cookies on your web browser.

When you are signed into a NewsNow account, we store some of this information on our servers instead, in a manner that links it to your NewsNow account, so that it can be shared between different devices from which you have signed in.

Cookies more generally

For further details of how we use cookies on our site, please see our
Cookie Policy.

Children’s data

Our sites are not aimed at under-18s. Some content that is accessible on or via our sites will not be appropriate for children
under the age of 18.

Special data

We do not seek to collect any special categories of personal data about you: those would include details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data. Nor do we seek to collect any information about criminal
convictions and offences. If, however, when using any interactive feature of the site (such as an online contact form), you
in fact provide us with any such special data or information about criminal convictions and offences, then by submitting such
data/information, we’ll assume that you are fine with our use of such data/information for (a) the purpose for which
you have voluntarily provided such data/information and (b) any purpose that is reasonably compatible with such purpose. You
may withdraw that permission at any time by contacting us: please see section 9 below for our contact details.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide
that data when requested, we may not be able to perform the contract that we have or are trying to enter into with you (for
example, to provide you with services). If so, we shall notify you if this is the case at the time.

3 How we use your personal data

We shall only use your personal data when the law allows us to do so.

We have set out below a description of all the ways that we plan to use your personal data, and which of the legal bases we
rely on to do so. We have also identified what our legitimate interests are where
appropriate.

Please note that we may process your personal data for more than one legal ground depending on the specific purpose for which
we are using your data. Please contact us if you need details about the specific legal ground that we are relying on to process
your personal data where more than one ground has been set out below.

Processing purposes

Analytics and web logs

When you visit our sites, we use analytics tools to collect, store and analyse standard web log data, which includes the web
page you have requested, the web page from which you clicked a link to NewsNow (if applicable), your computer’s public
IP address, your web browser’s name and version number, and your device’s operating system, and any cookies we have
stored when you have previously accessed our sites (if you haven’t configured your browser to refuse to store them).

In order to diagnose bugs, to gain a better understanding of usage patterns, and to identify and block abusive patterns of
access, our analytics tools generate and store a unique browser identifier in a persistent cookie on your browser, which we log
with each web page you request. This lets us distinguish unique users and link the log data we collect when you visit the site,
with the log data from your previous and subsequent visits.

Our log data are only collected and processed in a way that does not identify anyone. We do not make any attempt to link this
data to any personally identifiable information you might give us when submitting an online enquiry, subscribing to our
newsletter, or signing up for or into a NewsNow account (except as NewsNow account features require – see below).

We operate an in-house analytics tool as well as a third-party analytics tool called Google Analytics, a service run by Google
acting under contract as a data processor. Your IP address is anonymised when processed by Google Analytics. We store your full
IP address in our in-house web logs to allow us to identify and block abusive patterns of access. We also determine your country
and city from your IP address, to understand usage patterns.

We retain our own in-house web log data records for around 30 days. Google Analytics does not allow us to access individual web
log records. We retain aggregated and anonymised log data indefinitely in our in-house analytics tool and in Google Analytics.

We use those tools to allow us to diagnose bugs when they occur, to identify and block abusive patterns of access in order to
maintain the security and performance of our sites, and to improve our services through understanding usage patterns.

‘My Most Viewed’ menu

As you browse news topic pages, we store a record of your most commonly and recently accessed topic pages. We use this information
to construct the My Most Viewed menu of commonly and recently viewed topics.

Your publication preferences

If you opt to hide or highlight any news publications, we store a list of those so we can hide and highlight your selected
publications accordingly. Occasionally, we may also compile aggregated anonymised statistics of which publications are most
often hidden or highlighted in order to make better decisions about which publications to feature on our sites.

Legal basis for processing (including basis of legitimate interest):
Necessary for our legitimate interests (to improve your experience of the site and to improve our sites and services)

Tickers and alerts

When you dismiss a news ticker or alert, we may store a note of this so as to know not to show you that ticker or alert again.

Recent classified ad searches

On NewsNow Classifieds, we store a list of your most recent searches. We use this information to make it easier for you to
search again for the same things, and to show you the number of new classified ads matching your recent searches since your
previous visit.

Other functionality relying on cookies

Our sites also rely on storing data in other persistent and non-persistent browser cookies (known as session cookies) in order
to provide other functionality. Please see our Cookie Policy for more details.

Legal bases for processing (including basis of legitimate interest):
Necessary for our legitimate interests (to improve your experience of the site and to improve our sites and services)

When you submit an online enquiry

We request and store your name and email address, and optionally your telephone number, company/organisation, position/job
title and details of your enquiry, so that we can respond to your enquiry.

We will also collect some standard analytics and web log data (as explained above) and we may use it to better process your
request, but we do not collect any data that would allow us to link your enquiry to any other web log records of your use
of our sites.

We retain enquiry records indefinitely to allow us to identify patterns in reported issues, and to maintain our relationship
with repeat enquirers.

When you sign up for, and sign into, a NewsNow account

When you sign up for a NewsNow account (which is separate from a NewsNow Classifieds account), you enter into a contract for
the provision of additional features on our sites, which includes:

When you are signed into a NewsNow account, we store your preferences and some aspects of your browsing behaviour on our servers,
linked to your NewsNow account, so that those can be shared between different devices from which you have signed in.

When you view articles on NewsNow, we store which ones you viewed to provide the “Recently Read” feature.

We request and store your email address so that we can identify you when you want to sign into your NewsNow
account, send you emails directly related to the security or maintenance of your account or changes in functionality available
to NewsNow account holders. In certain cases, these emails may also include news about other developments at NewsNow or
its services.

We retain your NewsNow account data until you close your NewsNow account.

Legal bases for processing (including basis of legitimate interest):
(a) Necessary for the performance of our contract (processing of your NewsNow account data in connection with that contract)
(b) Necessary for our legitimate interests (for news about such developments)

When you subscribe to one of our newsletters

We request and store your name and email address so that we can deliver our newsletters and address you correctly. We use
in-house tools and a third-party provider, MailChimp, to deliver our email newsletters. When you open an email or click on
a link embedded in an email, we gather statistics using industry-standard technologies, including clear gifs to help us
monitor and improve our e-newsletter. For more information, please see MailChimp’s Privacy Policy and Cookie Policy.

When you submit your publication to be featured on NewsNow

When you apply for your publication to be featured on NewsNow, you do so pursuant to a contract between the publisher of your
publication and NewsNow.

We request and store your name, email address and telephone number, details of (and your job title in respect of) the organisation
and publication you represent. We use this information to process and assess your application, to contact you in relation to your
application, and should your application be successful, to contact you in relation to your publication’s inclusion on NewsNow.

So that we can identify you when you submit your application, or submit requests concerning your publication, we require you to have
signed up for, and be signed into, a NewsNow account.

We will also collect some standard analytics and web log data (as explained above) and we may use it to better process your
application, but we do not collect any data that would allow us to link your application to any other web log records of your
use of our sites.

We retain records indefinitely to allow us to identify patterns in applications, in issues reported by publishers or by others
concerning publication quality, and to maintain our relationships with publishers.

Legal bases for processing (including basis of legitimate interest):
(a) Performance of the publisher contract (where you yourself are the publisher of the publication)
(b) Necessary for our legitimate interests (in processing your application, where you are a representative of the publisher of the publication)
(c) Necessary for our legitimate interests (to improve your experience of the application process and to improve our sites and services)

When you subscribe to a NewsNow Classifieds email alert

We request and store your email address and classified ad search terms so that we can deliver the email alert(s) you’ve
requested and to provide you with access to a part of the website (known as your NewsNow Classifieds account – which is separate
from a NewsNow account) that allows you to administer your email alerts.

We may also email you to inform you of matters relating to the security or maintenance, or changes in functionality, of your
NewsNow Classifieds account. Our email alerts may also include information about other NewsNow services. We use in-house tools
to deliver our email alerts.

When you open an email or click on a link embedded in an email, we gather statistics using industry-standard technologies
including clear gifs to help us monitor and improve our NewsNow Classifieds email alerts. You can optionally provide us with
a password, so that we can identify you when you want to sign into your NewsNow Classifieds account via our website.

We retain such personally identifying data as long as necessary to provide the service you’ve requested. After you have
unsubscribed from all email alerts, we will retain such data for around 30 days (except when you have provided a password, in
which case we will retain such data for 6 months). NB: we will unsubscribe you from all email alerts if we have seen no activity
from you (e.g. you have not clicked on any link in the alerts, or signed into your NewsNow Classifieds account) for 6 months.

When you sign up for, and into, a NewsNow Classifieds account

We request and store your email address (if not already provided) and a password, so that we can identify you when you want
to sign into your NewsNow Classifieds account (which is separate from a NewsNow account) to administer any NewsNow Classifieds
email alerts you may subsequently request.

We retain such data in accordance with the description given in the row above.

Legal bases for processing (including basis of legitimate interest):
(a) Necessary for our legitimate interests (for the administration of the account and provision of such information)
(b) Consent (to deliver such email alerts)

When you contact us via social media

If you send us a private or direct message via a social media platform, a copy of the message may be sent to us by email as if
you had emailed us directly (although without your name or email address if the social media platform does not store or
forward this information).

We retain enquiry records indefinitely to allow us to identify patterns in reported issues, and to maintain our relationship
with repeat enquirers.

Legal bases for processing (including basis of legitimate interest):
(a) Consent (if given to the social media platform to do so)
(b) Necessary for our legitimate interests (in receiving the copy of that message)

When you email us directly

We use your email address, your name if you include it, and any other data you may include, to respond to your enquiry.

We may retain enquiry records indefinitely for as long as reasonably required for us to identify patterns in reported issues,
and to maintain our relationship with repeat enquirers.

We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS,
please be aware that any emails we send or receive may not be protected in transit.

We may monitor emails sent to us, including file attachments, for viruses or malicious software.

When you write to us by post or telephone us

We may retain correspondence with you when you write to us by post, as well as records of any correspondence by telephone.

We may retain enquiry records indefinitely for as long as reasonably required for us to maintain such correspondence.

Legal bases for processing (including basis of legitimate interest):
(a) Consent (to respond to any enquiry that you may make during such correspondence)
(b) Necessary for our legitimate interests (in those other respects, i.e. to improve your experience of the correspondence
process)

When you apply for employment at NewsNow

When you apply for employment at NewsNow, you do so in anticipation of potentially entering into a contract between
yourself and NewsNow.

In connection with that, we request and process various personal data.

During the application process we will collect, use and store your data for a number of main purposes. We request and process
your email address and telephone number so that we may initiate and maintain contact with you during the recruitment process.
We request your CV, to assess the experience you have which may be relevant for the role. We request a covering letter, to
assess your interest in and suitability for the role. We may ask you to complete exercises, to attend interviews, and to submit
references, all of which are also intended to assess your suitability for the position.

We retain your application data while processing your application.

If you are successful in your application to join the team at NewsNow, we will request further information from you, full
details of which will be made available at the time.

If you are unsuccessful, we will retain your application data on file for up to three years to allow us to process any future
application you might submit to us more efficiently, to ensure we are in compliance with appropriate and legal selection
processes, and (with your consent) to contact you again with regard to other suitable roles we may have in the future.

At the time you submit your application online, we will also collect some standard analytics and web log data (as explained above)
and we may use it to process your request more efficiently, but we do not collect any data that would allow us to link your
application to any other web log records of your use of our websites.

Legal bases for processing (including basis of legitimate interest):
(a) Necessary in connection with the potential entry into a contract or, if concluded, performance of our contract with you
(b) Necessary for our legitimate interests (in other respects while we are considering your application and in connection
with any such future interaction with you)

Online advertising

We may serve personalised advertising content on web pages that you visit on the site, in which case we and/or our ad network
partners may use personal data relating to you to generate such personalised advertising content.

Please note that our operations are funded by online advertising. We work directly with many firms (partners) to get the best
value from our ad space. Some, known as ‘exchanges’, resell our ad space in a global market of products and services of
brands and retailers, through their own direct relationships with those brands/retailers or other firms that represent them.
Other partners provide us with other services, such as ad serving.

Our exchange partners may perform some of the following activities:

Collecting and processing information about your use of our sites with the aim of subsequently personalising advertising
for you on our sites, or in other contexts, such as on other sites or apps. Typically, the pages of our site that you
access are used to make inferences about your interests, which when combined together (to create a profile) inform
future selection of advertising.

Selecting and delivering advertisements to you. This includes using contextual information about the pages of our site
that you access, which may be combined with previously collected information about you to select ads.

Measurement of delivery and performance of ads and user activity, which includes processing data about what ads were
shown, how often they were shown, when and where they were shown, and whether you took any action related to the ad,
such as clicking an ad or making a purchase.

Our partners, in performing any of the above activities, do so where either they have independently obtained consent (which
we may have facilitated) or have established a legal basis other than consent for those activities.

Our main partners include the following, and please see their own privacy policies for further details of their
own privacy and cookies practices:

Legal bases for processing (including basis of legitimate interest):
(a) Consent (in relation to the serving of personalised ads and the setting of related cookies, where you have given such consent)
(b) Necessary for our and our partners’ legitimate interests (in relation to the serving of such advertising
content, which supports us in providing you with our free services via the sites)

Other marketing

You may receive direct marketing emails from us if you have consented to receive those or if those relate to our services where
you have bought similar services from us and, in each case, you have not opted out of receiving that marketing.

NB: we will never share your personal data with any third party outside the NewsNow group of companies for the purposes of such
direct marketing emails, unless you have given your prior opt-in consent to do so.

Change of purpose

We shall only use your personal data for the purposes for which we collected the data, unless we reasonably consider that
we need to use such data for another reason and that reason is compatible with the original purpose. If you would like to
get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we shall notify you and explain the legal basis on which we
intend to rely.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if
and to the extent that this is required or permitted by law.

4 Disclosures of your personal data

We may share your personal data with the third parties set out below for the purposes set out in
section 3 above. We require all such third parties to respect the security of your personal data and
treat it in accordance with the law.

Internal third parties

Members of our group of companies from time to time, which provide certain operational and administrative services
to us and are based in the EU.

External third parties

Organisations we work with that receive or process personal data on our behalf under contract, including:

Google DFP, a supplier of advertising services, which is co-controller of the personal data and based in the USA.

MailChimp, an email delivery provider, a processor of the personal data and based in the USA.

Google Cloud and Amazon Web Services, which provide cloud hosting services to provide components of our technical
infrastructure, and may from time to time provide any aspect of site functionality and process personal data
accordingly as described above, within the EEA.

Independent contractors and virtual assistant firms that provide support services to our recruitment efforts,
acting as processors or separate controllers.

Our professional advisers (including accountants, lawyers and insurers), based in the UK, acting as processors
or separate controllers, which may in certain circumstances require disclosure of information in order to provide
their professional services.

Regulatory bodies and other authorities, based in the EU, acting as processors or separate controllers, which may
require reporting of processing in certain circumstances.

Other disclosures

In addition to the disclosures reasonably necessary for the purposes identified elsewhere in this Privacy Policy, we may share
your personal information if we believe in good faith that access to or use, preservation or disclosure of such information is
reasonably necessary: (a) to satisfy any applicable law, regulation, legal process or enforceable governmental request; (b) to
enforce any contractual rights that we may have in relation to the services we provide to you; (c) to detect, prevent or
otherwise deal with fraud, security or technical issues; or (d) to protect against harm to the rights, property or safety of
NewsNow, our employees or contractors, our business partners, our users or the public.

If we become involved in any prospective or actual transaction with a third party relating to our company, our business or
substantially all our assets, we may share your personal information with that third party. We will endeavour to ensure the
confidentiality of any personal information involved in such a transaction until (if at all) such personal information is
transferred and becomes subject to a different privacy policy.

5 International transfers

Some of the disclosures described above may involve a transfer of data outside the European Economic Area (“EEA”).

Whenever we transfer your personal data out of the EEA, we strive to ensure that a similar degree of protection is afforded
to such data by ensuring that at least one of the following safeguards is implemented:

transferring data to a provider based in the USA, if such provider adheres to the
Privacy Shield framework,
an agreement between the EU and the USA designed to protect data transferred between the two regions;

transferring your personal data to a country, organisation or sector that has, at the time of transfer, been deemed to
provide an adequate level of protection for personal data by the European Commission; and/or

using specific forms of contract approved by the European Commission that give personal data the same protection it
within Europe.

For further details of such safeguards, please see the European Commission’s website.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal
data out of the EEA.

6 Data security

We have put in place appropriate security measures (including user authentication software and secure data-sharing feeds) to
prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have
a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of
confidentiality.

We have put in place procedures to deal with any suspected personal data breach, and we shall notify you and any applicable
regulator of a breach where we are legally required to do so.

7 Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected such data, including
for the purposes of satisfying any legal, accounting or reporting requirements.

In some circumstances you can ask us to delete your personal data: please see section 8 below for further
information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information indefinitely without further notice to you.

8 Your legal rights

You may have the following rights (which may, in certain circumstances, be subject to certain exceptions under data protection laws):

(a) Right to be informed — you have the right to be told how your personal information will be used.
This Privacy Policy and other policies and statements used on our sites and in our communications are intended to provide you
with a clear and transparent description of how your personal information may be used.

(b) Right to withdraw consent — where we rely on your consent to use your personal information, you
have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information
for direct marketing purposes or to be unsubscribed from our email list at any time. This will not, however, affect the lawfulness
of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide
certain content or services to you. We shall inform you if that is the case at the time when you withdraw your consent.

(c) Right to access — you can write to us to ask for confirmation of what information we hold on you
and to request a copy of that information. We may need to seek evidence that you are entitled to see the information requested
and to confirm your identity.

(d) Right to rectification — if our records of your personal information are inaccurate, you have the
right to ask for those records to be updated. We may need to verify the accuracy of the new data that you provide to us.

(e) Right to erasure — you can ask us for your personal information to be deleted from our records where
(i) there is no good reason for our continuing to process such data, (ii) you have successfully exercised your right to object
to processing (see below), (iii) we may have processed your information unlawfully or (iv) we are required to erase your personal
data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for
specific legal reasons, which will be notified to you, if applicable, at the time of your request.

(f) Right to restrict processing — you may have the right to ask for processing of your personal data
to be restricted, where (i) you would like us to establish the accuracy of such data; (ii) our use of the data is unlawful,
but you do not want us to erase the data; (iii) you need us to hold the data even if we no longer require the data as you need
the data to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data, but we need to
verify whether we have overriding legitimate grounds to use the data.

(g) Right to data portability — where we are processing your personal information (i) with your consent,
(ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your
request before entering into a contact or (iii) by automated means, you may ask us to provide it to you – or to another service
provider – in a machine-readable format.

(h) Right to object to processing — you may have the right to object to processing of your personal data
where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation
that makes you want to object to processing on this ground as you believe that it affects your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

(i) Right to not to be subject to automated decision-making where that would have a significant effect on you.
We do not in fact engage in such activities, so this right will not, in practice, be relevant in the context of your use of our
sites.

To exercise these rights, please send a description of the personal information in question using the contact details at
section 9 below. Where we consider that the information with which you have provided us does not enable us to
identify the personal information in question, we reserve the right to ask for (i) personal identification and/or (ii) further
information.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge
a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your
request in those circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request
is particularly complex or you have made a number of requests. In this case, we shall notify you and keep you updated.

10 Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If so, we will post the revised version on our sites. You are encouraged
to check the terms of such revised versions. If the changes are significant, we will provide a more prominent notice and/or
email notification of the changes. Each version of this Privacy Policy will be identified by its effective date, and we will
also keep previous versions of this Privacy Policy in an archive for your review.

By clicking "OK" or continuing to use this site, you agree that we may collect and use your personal data and set
cookies to improve your experience and customise advertising. To see how, and to learn how to control cookies,
please read our Privacy Policy and
Cookie Policy.

By clicking "OK" or continuing to use this site, you agree that we may collect and use your personal data and set
cookies to improve your experience and customise advertising. To see how, and to learn how to control cookies,
please read our Privacy Policy and
Cookie Policy.